Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Rental receipts from the assessee's property were held to retain the character of income from house property because the assessee had consistently offered them under that head in earlier scrutiny assessments and the Revenue gave no basis to treat them as business income; deduction under section 24(a) was therefore allowed. The Tribunal also held that expenditure on renovation and erection of a temporary office structure, supported by bills and vouchers, was incurred to facilitate business more efficiently and was not shown to create an enduring capital asset; depreciation on the temporary structure was accordingly allowable.
Rental receipts from the assessee's property were held to retain the character of income from house property because the assessee had consistently offered them under that head in earlier scrutiny assessments and the Revenue gave no basis to treat them as business income; deduction under section 24(a) was therefore allowed. The Tribunal also held that expenditure on renovation and erection of a temporary office structure, supported by bills and vouchers, was incurred to facilitate business more efficiently and was not shown to create an enduring capital asset; depreciation on the temporary structure was accordingly allowable.
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